The European Union revised its regulations to allow insects as feed for aquaculture. Insect protein producers are celebrating the new market but continue to push for further acceptance. The next target is regulations on feed for poultry and pigs. Wild poultry will consume insects as a substantial part of their diet. Pigs are noted for rooting in the soil eating plant roots and soil insects. Insects are a natural part of the diet of these animals. Does it make sense to forbid feeding them insects as part of rearing them to market?

The FDA sets limits on acceptable insect damage in raw foods. Insect feeding damage on filbert nuts (aka hazelnuts) in the field can lead to discoloration and rancidity. Customers would not wish to purchase the nuts, but the damage can only be detected after the nuts are opened. It would be inconvenient for hundreds of customers to purchase rancid nuts and try to return them or do nothing and lose their money. Purchasing rancid nuts would hurt the market for nuts that are grown without pest damage. A consumer needs information for purchase decisions. One FDA role is to provide that information.

The FDA will inspect nuts to determine if they meet the standard, in this case, less than 10% damage. It is not possible nor practical to crack all the nuts.
What to do?
Subsample.
The FDA has a protocol of progressive subsampling. Out of a shipment, 100 nuts are taken at random and inspected. If 5 or fewer nuts have insect damage, the shipment meets the standard (less than 10%) and sampling stops. If 15 or more nuts have insect damage, the shipment does not meet the standard and is rejected. If the damage is between 6 and 14 nuts, more sampling is needed.

An additional 50 nuts are inspected. 10 or less and the shipment meets standards. 19 or more rejects the shipment, and 11-18 means 50 more nuts are to be sampled. Up to 7 rounds of additional sampling (500 nuts total) may be necessary. These procedures help insure our food quality, in spite of unpreventable insect damage.

Not all insect contamination of food is the same. Although most insects are not harmful, some can cause illness or medical harm. For example, some dermestid beetle larvae have barbed hairs that serve as protection against predation. The hairs can dislodge during processing of infested grain. If eaten, the hairs can catch the lining of the intestine. Lodged hairs can irritate the bowels and cause digestive illness. It is important to manage stored foods to prevent infestation by these beetles.

The US Food and Drug Administration regulates contaminants in food including insects and insect parts. As discussed in a previous post some contamination of our food by insects is unavoidable. However, the amount of contamination can be limited by good processing practice. The FDA created the Food Defect Action Level as a legal standard that processors must meet through good sanitary practices. Contamination above the allowable level is considered evidence of unsanitary processing conditions. Products processed under unsanitary conditions can be recalled and fines can be imposed. Products that do not meet the standard cannot be mixed and diluted in order to meet the standard. If a product deemed unsanitary is mixed with a sanitary product the new product is still deemed unsanitary even if the insect parts are now with the defect standard.

The regulations are available on the FDA website under Title 21, Subpart G: Defect Action Levels. The FDA issues guidelines in to accompany the regulation. The guidelines can be altered to meet changes. For example, a new invasive pest may cause additional unavoidable contamination and the guidelines adjusted accordingly. Or, new technology may greatly decrease the levels of contamination that can be obtained by good practice and the guidelines adjusted downward. Is it burdensome for processors to meet these regulations? Somewhat. However, having regulations and standards gives the public greater confidence in the food supply. Enforced standards prevent a race to the bottom with processors that don’t follow good practice undercutting the price of those conscientious processors who are using good practices. These regulations have widespread public support.

TITLE 21–FOOD AND DRUGS
CHAPTER I–FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF HEALTH AND HUMAN SERVICES
SUBCHAPTER B–FOOD FOR HUMAN CONSUMPTION

PART 110 CURRENT GOOD MANUFACTURING PRACTICE IN MANUFACTURING, PACKING, OR HOLDING HUMAN FOOD

Subpart G–Defect Action Levels

Sec. 110.110 Natural or unavoidable defects in food for human use that present no health hazard.

(a) Some foods, even when produced under current good manufacturing practice, contain natural or unavoidable defects that at low levels are not hazardous to health. The Food and Drug Administration establishes maximum levels for these defects in foods produced under current good manufacturing practice and uses these levels in deciding whether to recommend regulatory action.

(b) Defect action levels are established for foods whenever it is necessary and feasible to do so. These levels are subject to change upon the development of new technology or the availability of new information.

(c) Compliance with defect action levels does not excuse violation of the requirement in section 402(a)(4) of the act that food not be prepared, packed, or held under unsanitary conditions or the requirements in this part that food manufacturers, distributors, and holders shall observe current good manufacturing practice. Evidence indicating that such a violation exists causes the food to be adulterated within the meaning of the act, even though the amounts of natural or unavoidable defects are lower than the currently established defect action levels. The manufacturer, distributor, and holder of food shall at all times utilize quality control operations that reduce natural or unavoidable defects to the lowest level currently feasible.

(d) The mixing of a food containing defects above the current defect action level with another lot of food is not permitted and renders the final food adulterated within the meaning of the act, regardless of the defect level of the final food.

In the 1850s, Mormon settlers new to Utah described a plague of insects that were destroying their crops. The insects were given the name, “Mormon Crickets” and it has stuck for over a century even though the insects are not crickets or Mormon. Insect pest management specialists insist on calling them “Shield-backed Katydids” but that term has less penetration of the public lexicon than the term “entomologist”.

Residents of Arlington, Oregon are experiencing an outbreak, this summer (2017). The insects form clouds on the roads that can cause cars to lose traction. Drivers are encouraged to slow down if the road appears to move. My personal experience in driving through an insect swarm in Colorado resulted in a detour to a local car wash. The Shield-backed Katydids will enter homes through open doors, windows and garages. People who leave windows open at night may find a surprise the next morning. The insects are difficult to treat. Spraying the swarm in front of your house only works on those insects. The next day, they will be replaced as the swarm marches on. Some farmers cannot spray because they depend on bees to pollinate their alfalfa and other crops, creating a dilemma. The potential economic damage to crops is real. Other damage is largely aesthetic and ephemeral.

Fortunately, outbreaks do not occur every year and populations often crash due to increased disease transmission in dense populations. For now, the residents are miserable, but most insect plagues pass quickly.

Bees collect pollen to feed to their brood. Without pollen, the brood starves and the bees are eliminated. In their native habitats, bees encounter a variety of plants with differing phenologies. Some flower early, some midseason and some flower late. Together, these plants supply a continuous source of pollen. In agroecosystems, as vast area may be cultivated with a single plant. For instance rape seed flowers early for a few weeks, then sets seed. It requires pollinators but only flowers for a few weeks. Bees can collect substantial pollen in spring only to starve in summer into fall.

However, if the agroecosystem is managed to include both blocks of rape seeds and blocks of sunflowers, the sunflowers will provide pollen after the rape seed is finished flowering. Borders and fence rows that contain flowering plants can provide a bridge food for bees if a gap occurs. Bees are an important component of food production. Plants with inadequate pollination will have lower yields. By managing the landscape to encourage bees, farmers can improve their yields and profits.

80% of the world population eats insects intentionally; 100% eat insects unintentionally.

Grasshopper

Consuming insects is unavoidable because insects contaminate many food items. Even under the careful eye of the home gardener, Drosophila flies will lay eggs on ripening tomatoes. These eggs often hatch before the tomato is eaten and tiny Drosophila larvae are invariably consumed. It is not practical to grow tomatoes and exclude insects (How would they be pollinated?). People have been eating home grown tomatoes for centuries and the insects are mostly unnoticed and ignored.

If ripe tomatoes are split and crawling with large numbers of large Drosophila larvae the tomatoes are usually discarded. The standard accepted practice is to ignore small numbers of rarely noticed small larvae but reject produce with noticeable size and numbers. This standard is met by regulations for processed tomatoes in the US. The U.S. Food and Drug Administration (FDA), recognizes the impossibility of excluding all insects and insect parts from foods. Instead the FDA regulates the maximum level of insects and insect parts in commercially sold food.

The FDA demands that food be prepared under sanitary conditions and excessive insect parts in commercial foods is interpreted as evidence of unsanitary food preparation conditions. The U.S. FDA publishes “Food Action Defect Levels” and will recall food that exceeds those limits. Small amounts of insects and insect parts in food below the FADL are not considered harmful.

Companies that process and market food to the public typically take measures to keep insects contamination far below the FDA standards. A violation could generate negative press that could reduce sales and profits. Consumers sometimes file lawsuits when they find insect contamination in processed foods. For example, a grasshopper the size of a green bean may not be mechanically excluded from the processing. A consumer who found a grasshopper in a can of beans sued the company. Consumer dissatisfaction motivates the food processing industry to exclude insect contamination levels that might comet to the attention of consumers.